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Planning for Compensatory Grants of Partnership and LLC Interests
Posted by Robert Kerr on Wed, Mar 15, 2017 @ 03:06 PM

Partnerships and LLCs have the opportunity to make grants of ownership interests tax-efficient with Internal Revenue Code (IRC) Section 83(b) ("Section 83(b) election").  

Business entities operating as partnerships for federal tax purposes, including LLCs often consider the grant of an ownership interest in the business as additional incentive compensation for valued employees or contractors. Partnerships may offer ownership interests in the form of a profits interest or a capital interest. On the surface, this appears to be an easy and flexible way of providing a benefit to personnel without affecting current cash flow. There are traps for the unwary, however. Proper structuring of these transactions is critical to ensure optimal tax consequences for both the partnership and the recipients of these awards.

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Topics: Robert Kerr, IRS, Partnerships, LLC, Section 83(b), Rob Kerr

FBAR Filing Reminders for the Upcoming June 30 Deadline
Posted by Robert Kerr on Wed, Mar 16, 2016 @ 08:00 AM

The deadline for filing the Form 114, Report of Foreign Bank and Financial Accounts (FBAR), is rapidly approaching. Introduced in September 2013 by the Financial Crimes Enforcement Network (FinCEN), the Form 114 FBAR helps monitor U.S. persons’ activity in foreign bank accounts.

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Topics: Robert Kerr, FBAR

Reminders for FBAR Filing for the Upcoming June 30 Deadline
Posted by Robert Kerr on Wed, Mar 25, 2015 @ 01:33 PM

114 Electronic Filing Requirement

In September 2013, the Financial Crimes Enforcement Network (FinCEN) introduced Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Form 114 is still required to be submitted to FinCEN before June 30, but it now must be filed electronically by using a registered tax software program or by using the Bank Secrecy Act (BSA) E-filing System: http://bsaefiling.fincen.treas.gov/main.html. The electronically filed Form 114 replaces Treasury Department Form 90-22.1, which was paper filed with FinCEN in previous years.

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Topics: Robert Kerr, FBAR

Do Your Withholding Processes Comply with FATCA?
Posted by Robert Kerr on Thu, Dec 11, 2014 @ 09:17 AM

FATCA Targets Tax Evasion

The recently enacted Foreign Account Tax Compliance Act (FATCA) added a chapter to the Internal Revenue Code designed to prevent U.S. persons from using offshore accounts and investments to evade U.S. tax. Effective July 1, 2014, any person making a payment of U.S. source income to either a Foreign Financial Institution (FFI) or a Non-Financial Foreign Entity (NFFE) must consider whether it is subject to FATCA.  

U.S. entities, both financial and non-financial, that make payments of U.S. source income to non-U.S. persons will be affected. There is a potential 30% U.S. withholding tax imposed on U.S. source "withholdable payments" made to a non-U.S. entity under FATCA. The U.S. payor will need to understand the entity classification of its non-U.S. payees under FATCA and will be required to maintain documentation on these non-US persons.

Since the new FATCA requirements did not replace the existing withholding rules on payments of certain U.S. source income to non-U.S. persons, businesses are currently reviewing their processes to ensure proper compliance with the existing withholding rules as well as the new FATCA provisions.

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Topics: FATCA, Robert Kerr

Notable Changes to FBAR Filing for the Upcoming June 30 Deadline
Posted by Robert Kerr on Thu, May 29, 2014 @ 09:23 AM

New Form 114 Electronic Filing Requirement

In September 2013, the Financial Crimes Enforcement Network (FinCEN) introduced Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Form 114 is still required to be submitted to FinCEN before June 30, but it now must be filed electronically by using a registered tax software program or by using the Bank Secrecy Act (BSA) E-filing System. The electronically filed Form 114 replaces Treasury Department Form 90-22.1, which was paper filed with FinCEN in previous years.

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Topics: Robert Kerr, FBAR, Form 114

IRS Issues Final Section 382 Regulations for Loss Corporations with Small Shareholders
Posted by Robert Kerr on Fri, Jan 17, 2014 @ 09:31 AM

The Treasury Department and IRS recently issued final regulations (T.D. 9638) under Section 382, which relate to the application of segregation rules to certain transactions involving public groups of small shareholders. These groups are comprised of shareholders who each own, directly or indirectly, less than five percent of the stock of the loss corporation.

The final regulations were published in the Federal Register on October 22, 2013 and generally follow the temporary regulations issued in 2011.

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Topics: Robert Kerr, IRS, IRS Updates

Important Update on FATCA Withholding Requirements
Posted by Robert Kerr on Wed, Jul 31, 2013 @ 09:04 AM

As discussed in previous blog posts, the Foreign Account Tax Compliance Act (FATCA) requires foreign financial institutions (FFIs) to report information about financial accounts held by U.S. taxpayers, as well as accounts held by foreign entities in which U.S. taxpayers hold a substantial ownership interest.

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Topics: Foreign Account Compliance, FATCA, Robert Kerr

FATCA Non-Compliance Triggers Harsh Penalties for Withholding Agents
Posted by Robert Kerr on Mon, May 13, 2013 @ 09:18 AM

Little Time Left for Withholding Agents to Prepare for Complicated FATCA Compliance Requirements

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Topics: FATCA, Robert Kerr, tax planning, tax, compliance, tax compliance

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